What is required for a payroll customer to qualify under Phase II?

To qualify under Phase II, a payroll customer must regularly withdraw more than $10,000 in cash. This requirement is tied to the regulatory focus on significant cash transactions, which are often indicative of money laundering or other illicit activities. By establishing a threshold of $10,000, the regulations aim to monitor and track larger cash movements that could pose a higher risk for financial crimes.

High cash withdrawals are scrutinized because they can come from various sources, and regular patterns of such transactions may suggest that the customer is engaged in business activities with substantial cash flows. Thus, monitoring these transactions helps to ensure compliance with anti-money laundering regulations and aids in the detection of suspicious activity that may need further investigation.